The Patient Protection and Affordable Care Act (PPACA) will introduce new marketplaces for individual and small group health insurance, effective January 1, 2014, in the form of public exchanges. Health insurance plans need to fully prepare for and understand the impact that the public exchanges may have on their business. Whether or not a health plan participates, the logjam that blocked reform progress for several months appears to have been cleared; PPACA is now moving forward with weekly releases of regulations and rules (most are preliminary rules and open for comments). This momentum of rule writing brings new terminology and issues to light, which are critical to understand before making decisions on whether or not to participate in the public exchanges.

This paper provides 10 critical considerations based on the preliminary rule recommendations published in the last half of November. As these rules are finalized, the considerations and market dynamics may change.